Selective Marketplace Limited trading as Wrap London ("we" or "us") takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services about our practices regarding the collection, use and disclosure of personal information which may be provided to us via our websites, associated apps and other digital products we provide or collected through other means such as an online form, email, or telephone communication.
This notice applies to information provided by our users, whether they are a customer or otherwise. In this notice "you" refers to any individual whose personal data we hold or process (other than our staff). In this notice references to the "Site" are references to any website, app or other means by which you provide personal data to us or access our services.
This notice is governed by the EU General Data Protection Regulation (the "GDPR") May 2018.
BASIS ON WHICH WE PROCESS PERSONAL DATA
Personal data we hold about you will be processed either because:
- you have consented to the processing for the specific purposes described in this notice;
- the processing is necessary in order for us to comply with our obligations under a contract between you and us; or
- the processing is necessary in pursuit of a "legitimate interest", a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security.
PERSONAL DATA WE COLLECT
We may collect and process the following personal data (information that can be uniquely identified with you) about you:
- log-in details and information you provide when setting up an account on the Site ("Login Information");
- profile information you provide to us relating to your account or profile with us ("Account Information");
- contact information we collect from you (for example, your name, address, telephone number, email address) ("Contact Information");
- information we collect which relates to orders you have placed with us, including products you have ordered, shipping destinations the price of products you have ordered and any customisation ("Order Information");
- information provided to us relating to payment including credit or debit card details ("Payment Information");
- a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us ("Communication Information");
- details of your visits to the Site, the resources and pages that you access and any searches you make ("Technical Information");
Generally we collect personal data directly, but we may obtain data from third parties from time to time. For instance we may licence data from a postcode database in order to ensure efficient shipping. If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
You do not have to supply any personal information to us but the Site may not be operable without providing data to us. In particular we will be unable to fulfil an order without collecting some personal data from you.
You may withdraw our authority to process your personal data (or request that we restrict our processing – see your privacy rights below) at any time but we will be entitled to complete any orders we are then processing and we may need to withhold some personal data for legal or other reasons.
A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
|CSPSESSIONID-SP-80-UP-||Remembers who you are for the duration of your visit and what is in your shopping bag. Contains no personally identifiable information or credit card details. The website wouldn’t work for you without them.|
|wrapUS||Allows us to remember what's in your shopping bag when you return to the site.|
|wrapgeoredirect||Allows us to remember your localised site choice.|
|pfustr||Necessary for the product review facility to work correctly.|
|__utma, __utmb||These cookies allow us to see how people use our site, for example how they get to our site, how long they spend on the site and whether they're first-time visitors.|
Once you close your browser, our access to the cookie terminates. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To change your browse settings you should go to your advanced preferences.
If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
HOW WE PROCESS YOUR PERSONAL DATA
Please see the table below, which sets out the manner in which we will process the different types of personal data we hold:
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|When you register with the Site||Login Information
|Performance of a contract with you
Necessary for our legitimate interests (to obtain necessary information in order to provide our services)
|When you update or amend your account details||Login Information
|Performance of a contract with you|
|When we fulfil an order for products placed with us||Login Information
|Performance of a contract with you
Necessary for our legitimate interests (for running our business and to provide you with products and services requested)
|When you seek to cancel or change an order||Login Information
|Performance of a contract with you
Necessary for our legitimate interests (for running our business and to provide you with products and services requested and to fulfil our statutory obligations)
Necessary to comply with legal obligation
|To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(c) When you submit a complaint
|Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use the services we provide)
|To administer and protect our business, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data||Login Information
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation)
Necessary to comply with a legal obligation
|To use data analytics to improve the Site, services, marketing, customer relationships and experiences||Technical Information
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
For any category of personal data not specifically defined in this notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
If you wish to request that data we hold about you is amended or deleted, please refer to 'Your Privacy Rights' below.
SHARING YOUR INFORMATION
We do not disclose any personal data you provide to any third parties other than as follows:
- If you place an order personal information relevant to your delivery will be provided to our shipping partner;
- We may host personal data with third party hosting partners;
- Certain third party suppliers including technical support providers may have access to personal data;
- where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal data itself) may be transferred to interested third parties;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
- in order to enforce any terms and conditions or agreements for our services that may apply;
- we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
- to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- When you first ordered from Wrap you were asked if you were happy to receive mailings and offers from third party companies. Third party companies are largely other mail order fashion businesses whose products we thought might interest you but also may include companies that sell homewares or garden furniture. Occasionally we may also make our mailing list available to established charities. We reach these other companies and charities directly or via a data co-operative. A data co-operative collects data and customer information across a range of different categories from a pool of UK retailers. Who then analyses that information to help the participating companies understand customers' wider buying patterns. This in turn enables companies to tailor their communications, sending people suitable offers based on what they like to buy.
See a list of the data co-operatives we participate in below:
We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers. The participating retailers are active in the following product categories: clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors.
They share information on what their customers buy. Epsilon Abacus analyses this pooled information to help retailers understand consumers’ wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.
To find new customers for our business we are a member of a large co-operative of like-minded UK retail brands that pool and share transactional information. We work with a program called iBehavior, part of the Company Conexance that processes customer transactional data on behalf of each member. This process highlights spending patterns and allows us to identify suitable prospects to receive an offer or introduction from us via the post. Thus, we send postal offers and information only to prospective customers that are likely to be interested in buying from us. Co-op member brands operate in numerous categories, including apparel, home and garden, collectables, food and wine, gadgets and gifts, entertainment, health and beauty, travel and leisure.
Your personal data is shared with Experian Ltd for the purposes of managing a service called Club Canvasse, a home shopping and direct retailer data co-operative of which Selective Marketplace Ltd are members. By sharing information on what customers buy and pooling that with contributions from other members of the co-operative, the service allows Selective Marketplace Ltd to better understand our customers and to communicate with you more effectively. To understand more please click through to their website here.
We will share your data with Transactis 2017 Ltd. who will use it to help direct marketing organisations such as ourselves better understand the likely characteristics of their customers; communicate with them more effectively; and also identify prospective customers. This should mean that you receive direct marketing that is more relevant to you. To understand more please click through to their website below: Transactis 2017 Ltd.
Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
UNSUBSCRIBING FROM OUR CATALOGUES
From time to time we will send you catalogues and promotions by post. If you no longer wish to receive postal mailings from us, please fill out and submit our online contact form with your name, address and account number, which can be found on the back of your latest catalogue. Please note catalogues are printed in advance so you may receive one further mailing after opting out.
UNSUBSCRIBING FROM OUR NEWSLETTERS
We will ask you for your email address so that we can send you an order confirmation and any further delivery information. From time to time we will send you special offers and promotions. If you no longer wish to receive these promotions, please click on the unsubscribe link at the bottom of any newsletter.
CAN I GO BACK ON YOUR MAILING LIST?
If you have previously asked us not to send catalogues and promotions by post or email but have changed your mind please fill out and submit our online contact form.
OPTING OUT OF THIRD PARTY MAILINGS
If you have now changed your mind and no longer want third party mailings, please fill out and submit our online contact form with your name, address and account number, which can be found on the back of your latest catalogue. Please note we never pass on your email address to third-parties for marketing purposes.
We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
- protecting our servers by both hardware and software firewalls;
- locating our data processing storage facilities in secure locations;
- encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
- disposing or deleting your data securely;
- regularly backing up and encrypting all data we hold.
We will ensure that our employees are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are also aware of their privacy and data security obligations.
This notice and our procedures for handling personal data will be reviewed as necessary.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorised access.
YOUR PRIVACY RIGHTS
The GDPR gives you the following rights in respect of personal data we hold about you:
|The right to be informed||You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.|
|The right of access||You can make what is known as a Subject Access Request ("SAR") to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.|
|The right to correction||Please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.
We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
|The right to erasure (the 'right to be forgotten')||Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible.
We will communicate the erasure to any third parties to whom we have passed the same information.
|The right to restrict processing||You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data.|
|The right to data portability||You have right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).|
|The right to object||Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted. You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes. Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds.|
|Rights with respect to automated decision-making and profiling||You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, it is permitted by law, or if you have given your explicit consent.|
|Right to withdraw consent||If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. Even if you have not expressly given your consent to our processing, you also have the right to object (see above).|
All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to The Data Protection Manager, Selective Marketplace Limited, 2 Rothley Lodge, Loughborough Rd, Leicester, LE7 7NL or by email at firstname.lastname@example.org. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.
Our Sites may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
In addition, if you came to this Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
TRANSFERRING YOUR INFORMATION OUTSIDE EUROPE
As part of the services provided to you the information you provide to us may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
We have customers who are outside of the EEA and in those circumstances personal data will be transferred outside of the EEA (for instance to shipping partners).
We will not transfer the personal data of EEA customers in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
- If you use our Site while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services;
- We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information) for example you may be outside of the EEA when we communicate with you;
From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.
If you would like to obtain details of the safeguards we have put in place then please contact us at: Selective Marketplace Limited, 2 Rothley Lodge, Loughborough Rd, Leicester, LE7 7NL email@example.com.
By submitting your personal information to us you agree to the transfer, storing or processing of your information outside the EEA in the manner described above.
NOTIFICATION OF CHANGES OF THE CONTENTS OF THIS NOTICE
We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via the following email address: firstname.lastname@example.org.
If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.